Annex I, accessibility requirements for products and services
Annex I Section II: Packaging and instructions
Packaging and the installation, maintenance, storage and disposal instructions must themselves be accessible, not only the product.
- Citation
- Annex I, Section II, CELEX 32019L0882 (Directive)
- Binds
- All products in Article 2(1) except the self-service terminals in Article 2(1)(b).
- In the instrument
- Annex I, accessibility requirements for products and services
- Applies from
- 28 June 2025 for products placed and services provided from that date (Article 31(2)). The Article 4(8) 112 duty may be deferred to 28 June 2027 where a member state uses Article 31(3).
- Source
- EUR-Lex, CELEX 32019L0882
What it requires
Section II adds packaging and lifecycle instructions to the Section I requirements for products other than self-service terminals. The aim is again foreseeable use by persons with disabilities.
Point (a) requires the packaging to be accessible, including the information it carries about opening, closing, use and disposal and, where provided, about the product's accessibility characteristics. Where feasible, that accessible information should be on the package itself.
Point (b) covers instructions for installation, maintenance, storage and disposal that are not on the product but are made available another way, such as a website. They must be public before the product is first supplied and must meet six qualities: more than one sensory channel; understandable presentation; presentation in a form users can perceive; adequate font size and shape for the conditions of use with sufficient contrast and adjustable spacing; text formats that can generate alternative assistive formats; and an alternative presentation of any non-text content.
In practice
The packaging review is often the quickest win. A carton that already carries a QR code can carry a short accessibility statement and a link to the full instructions, provided the link works and the information is available in more than one sensory form. Record the artwork version and the date the pack was changed.
What to do
- Review the packaging as a communication surface, not only as protection.
- Put accessibility information on the package where it can be done.
- Publish installation, maintenance, storage and disposal instructions when the product is placed.
- Apply the six presentation qualities to those instructions.
Evidence to keep
- Packaging artwork with the accessible information and a photograph of the pack.
- The published lifecycle instructions and their accessible formats.
- A readability check for font size, contrast and spacing.
- The alternative presentation for each diagram or icon.
Dates
- 2025-06-28Section II applies to products placed from this date except self-service terminals. (Article 4(2))
Cross-references
Where teams get this wrong
The self-service terminal carve-out is easy to over-apply. It removes Section II for the terminal, but the terminal still has to meet all of Section I, including its information duties.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Annex I, Section II. Check it yourself: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882. This page states the provision in our own words and is not legal advice; it does not certify any product or service.